Subject: File No. S7-04-11
From: Paul Woolsey

February 11, 2011

I have been an accredited investor for decades. My academic and business background is in finance. To include the value of an investor's residence in the calculation of their net worth for purpose of being qualified as an investor has always struck me as troublesome.

We have vividly established in the last few years the consequences of viewing a home as an investment to be leveraged and put at risk. I strongly support the proposed change and feel that the denial of inclusion of the value of home equity is a good step forward in protecting casual investors from inappropriate investments.